EXHIBIT 5
 
                     [WILLKIE FARR & GALLAGHER LETTERHEAD]
 
May 9, 1997
 
Fine Host Corporation
3 Greenwich Office Park
Greenwich, Connecticut 06831
 
Re: Public Offering of Common Stock
   of Fine Host Corporation
 
Ladies and Gentlemen:
 
    We have acted as counsel to Fine Host Corporation (the "Company"), a
corporation organized under the laws of the State of Delaware, in connection
with the preparation of a Registration Statement on Form S-1 and Post-Effective
Amendment No. 1 to the Registration Statement on Form S-1 declared effective on
February 28, 1997 (File No. 333-19909) (the "Registration Statement") relating
to the offer and sale by certain selling stockholders of up to 941,350 shares of
the Common Stock of the Company, par value $.01 per share (the "Shares").
 
    We have examined copies of the Restated Certificate of Incorporation and
By-Laws of the Company, the Registration Statement, all resolutions adopted by
the Company's Board of Directors and other records and documents that we have
deemed necessary for the purpose of this opinion. We have also examined such
other documents, papers, statutes and authorities as we have deemed necessary to
form a basis for the opinion hereinafter expressed.
 
    In our examination, we have assumed the genuineness of all signatures and
the conformity to original documents of all copies submitted to us. As to
various questions of fact material to our opinion, we have relied on statements
and certificates of officers and representatives of the Company and public
officials.
 
    Based on the foregoing, we are of the opinion that (i) the Company has been
duly organized and is validly existing as a corporation in good standing under
the laws of the State of Delaware and (ii) the Shares that are outstanding as of
the date hereof have been duly authorized, validly issued and are fully paid and
non-assessable.
 
    We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement, and to the reference to us in the Prospectus included as
part of the Registration Statement.
 
Very truly yours,
 
/s/ WILLKIE FARR & GALLAGHER
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